RV Park Feasibility Study: SBA or USDA B&I, and Why the Answer Changes the Study

A sponsor with an RV park at term-sheet stage in 2026 usually has two lenders in view, one under SBA 7(a) or 504 and one under USDA Business and Industry, and usually assumes the feasibility study serves both. It can, but the two programs disagree about what an RV park is. SBA finances it as a transient lodging business and disqualifies it the moment more than half its revenue comes from stays longer than 30 days. USDA finances it as a rural tourism and recreation enterprise and asks instead whether it creates jobs in an eligible area, whether the sponsor has the equity the rule requires, and whether an independent consultant acceptable to the State Office has proved the five components of feasibility. The choice determines the loan size, the term, the guarantee, the equity, who reviews the study, and, most consequentially, which version of the park the study is allowed to describe.

This is the reading we give lenders and sponsors on campground and RV resort files, current as of 7 September 2026, built from the two programs' rules, the public REIT filings, the KOA and OHI demand and benchmarking data, the Newmark expense and valuation surveys, and a tabulation of SBA's loan-level FOIA releases for the asset class. SOP 50 10 8.1 is noted where it changes the acquisition rules from 1 October.

What the two programs think an RV park is

SBA. An RV park or campground is an eligible active business under 7(a) and 504 only if it clears the passive-business bar. 13 CFR 120.110(c) makes ineligible "passive businesses owned by developers and landlords that do not actively use or occupy the assets," and SOP 50 10 8 applies that rule to lodging with a bright line: more than 50% of the business's gross annual revenue must come from transient guests staying 30 days or less. Up to 49.9% may be monthly, seasonal or annual site revenue; one point past the line and the park is treated as the passive rental real estate the SOP bars, in the same category as the mobile home parks it excludes outright. The SOP's special-purpose property list is non-exhaustive, and lenders commonly treat developed pads, bathhouses and utility infrastructure as limited-market collateral for equity and appraisal purposes. Maximum 7(a) loan $5 million, guaranty 85% to $150,000 and 75% above, real estate maturity 25 years, minimum 10% injection on start-ups and complete changes of ownership; since 4 July 2026 an eligible borrower may combine 7(a) and 504 exposure to $10 million.

USDA. Under 7 CFR 5001.105(b)(8), eligible Business and Industry projects include "tourist and recreation facilities, including hotels, motels, bed and breakfast establishments, and resort trailer parks and campgrounds operated as a public or private commercial enterprise," with the pro rata value of any owner's living quarters deducted from the use of proceeds. There is no transient revenue test. The tests are location, in a rural area outside a city or town of more than 50,000 and its contiguous urbanized area; ineligible purposes, which under the program exclude golf courses, racetracks and gambling facilities, so a park that bundles them has a carve-out to make; and capital, under Table 1 to 5001.105(d): 10% balance sheet equity for an existing business, 10% for a new business with adequate sales contracts, 25% for a new business requesting the guarantee before construction is complete, and 20% equity or 25% project investment for any other new business, with the Agency able to raise the requirement based in part on "the strength of the feasibility study and experience of management." Maximum $25 million to one borrower; FY2026 guarantee 85% on requests under $5 million and 80% at $5 million and above; initial guarantee fee 3% of the guaranteed amount, annual retention fee 0.55%; maximum term 40 years.

Why it matters. The same 150-site park can be an eligible SBA borrower and an ineligible one depending on how it books its sites, and an eligible USDA borrower or an ineligible one depending on which side of a city boundary it sits. Neither program cares what the other thinks.

The tenure paradox

The paradox is the structuring fact of the asset class and almost no one states it. Transient revenue carries the highest rate and the highest cost to earn it, and it concentrates in five months. On a representative northern seasonal park, roughly 60% of transient revenue lands from May through September while the four winter months carry about a third of the year's debt service; an annual coverage ratio of 1.5x can be entirely honest and the February payment can still bounce. The instrument that prevents that outcome is the contracted book: a healthy annual and seasonal roster can cover half or more of every month's debt service before a transient guest checks in. That is why both public REITs are converting toward annual tenure as fast as sites allow. In 2025 Equity LifeStyle's core seasonal and transient rent fell 9.1% while its annual RV base rent rose 4.1%; Sun Communities' transient RV revenue fell about 9% with RV segment same-property NOI down 1.4%; Campspot's booking network showed U.S. occupancy flat at 30.1% against 30.2%. The volatile layer softened and the durable layer grew.

The durable layer is also the layer SBA will not finance past 49.9% of revenue. A sponsor who engineers the park for coverage engineers it out of the cheapest fully amortizing 90% advance in the market. The consultant's first job, before a demand number is written, is to ask which park the sponsor is building: the SBA-eligible transient park that lives on its summer, or the USDA or conventional park that lives on its contracted book. The study that follows is different in each case.

The decision matrix

Location. Rural under the 50,000 test, and USDA is open; inside a larger town's urbanized area, and it is not. USDA's eligibility map answers the question in minutes and should be run before the engagement letter.

Tenure. Transient revenue above 50%, and SBA is open; below it, and the park is SBA-ineligible regardless of how well it performs. A park at 55% transient today that plans to convert toward annual tenure is eligible at closing and drifting toward a covenant the SOP does not police but the lender's file will show.

Size. 7(a) tops out at $5 million and the combined cap at $10 million; B&I reaches $25 million. A resort build at $40,000 to $70,000 a site all-in crosses the 7(a) line at roughly 100 sites.

Term and constant. SBA real estate paper runs 25 years; B&I runs to 40. At a 9.75% 7(a) ceiling the 25-year constant is about 10.7%; at negotiated B&I pricing over 40 years it is materially lower, and against Newmark's 8.0% going-in cap rate for Class A and B parks the difference is the difference between negative and neutral leverage on day one.

Guarantee and fees. 75% and a tiered upfront fee under 7(a); 85% under $5 million and 80% above with a 3% initial fee and 0.55% retention under B&I.

Equity. 10% under 7(a) on a start-up; 15% or 20% under 504 for special-purpose or start-up collateral; under B&I, 20% equity for a new business, 25% where the guarantee is requested before construction completes, and the Agency can raise it.

The study. Under SBA, at lender discretion, ordered in practice on every ground-up and most acquisitions because repayment rests on projections; under B&I, required on any loan over $1 million to a new business, prepared by an independent qualified consultant acceptable to the Agency, scoped by the Agency, and reviewed by the State Office before commitment.

Review and timing. A Preferred Lender controls the loan-number date and closes on its own calendar; USDA accepts applications year-round, reviews at the State Office, routes larger requests to the National Office, sends projects over $1 million adding more than 50 jobs to the Department of Labor, and treats any modification after a complete application as a new application.

Acquisitions from 1 October 2026. Under SOP 50 10 8.1 an Initial Acquisition is underwritten at 1.25x on trailing EBITDA with no projections credited, total debt capped at the appraised business value, and a lender-ordered quality of earnings report at a $3 million business price net of real estate. USDA has no equivalent; its acquisition test is the credit evaluation and the equity table.

What changes in the study

The five components. A USDA study is built to Appendix A of Part 5001: economic, market, technical, financial and management feasibility, with the factor list the State Office grades against, a signed recommendation and the author's qualifications. An SBA study has no codified structure and is built to the credit committee and the guaranty purchase reviewer. The safe construction is the USDA architecture with SBA's coverage floors laid on top: 1.15x for a Standard 7(a) loan, 1.10x for a Small Loan, 1.25x on history for an 8.1 acquisition.

Demand, and the number not to anchor to. Campground demand is a function of the installed base of roughly 8.1 million RV-owning households and how intensively they travel, not of the factory-to-dealer shipment flow. Wholesale shipments fell from 600,240 units in 2021 to 313,174 in 2023 and ran 342,220 in 2025, about 4.2% of the owning base; over the same period median annual RV usage rose from 20 days to 30, and KOA's 2026 report counts more than 52 million North American households camping in 2025, about even with the record years and above pre-pandemic, with $66 billion of community spending, glamping at 29% of experiences and 31% of campers planning more nights in 2026. A study that anchors demand to a shipment headline is wrong in both directions; one that anchors to the installed base and usage, then tests the transient layer against the REITs' 2025 softening, is defensible under either program.

Supply. No comprehensive private-campsite series exists. The trade's tracker documents roughly 5,716 new and expansion sites from 2024 through early 2026 against a standing base of about 1,520,000 private sites, net growth near 0.2% a year, with projects delayed by rates and inflation rather than permitting. The study has to count the trade-area pipeline itself, and under USDA it has to show the State Office that the new sites the loan funds are not displacing an existing rural operator's.

Tenure and seasonality, by month. Under SBA the study must document the transient share above 50% from the operating history or, on a start-up, from the site mix and rate plan, and it should show the lender the drift risk if the sponsor converts sites later. Under USDA the study can and should present the contracted book as the coverage instrument it is. Under both, coverage is shown by month, not by year: the trough month against the trough month's debt service, with the contracted book's share of that payment stated.

Rates and expenses. The national weighted average nightly rate ran $103.60 in July 2026 on the sector's new pricing index, with the median RV site at $62 and premium and waterfront sites 22% to 25% above standard. Full-hookup sites averaged 68% occupancy during operating months in OHI's benchmarking, and converting operating-season occupancy to a trailing-twelve-month figure overstates revenue by roughly a third in a seasonal market. The expense benchmark is Newmark's analysis of 62 parks and 10,682 sites: 53.7% of revenue, payroll 15.5% and utilities 14.5% the largest lines, with no reserve and no royalty in the schedule; a seller statement below 45% reflects unpaid owner labor and missing reserves and is restated before any coverage ratio is computed. Development cost runs about $30,000 to $40,000 a site excluding land for a good-quality 100-plus-site park and $40,000 to $70,000 all-in for resort product, and a resort build needs roughly $12,000 of revenue per site a year to clear a 10% to 11% yield on cost against the $5,000 to $10,000 operating parks achieve.

Floodplain, as a go/no-go screen. Waterfront commands the rate premium and takes the park. Under 44 CFR 60.3 an RV in a Special Flood Hazard Area escapes elevation requirements only if it stays fewer than 180 consecutive days or remains road-ready on its wheels with quick-disconnect utilities, and FEMA states that the National Flood Insurance Program does not insure recreational vehicles as buildings. The July 2025 Guadalupe River flood destroyed the Blue Oak RV Park in Kerrville; Hurricane Helene damaged all 38 of the Carolinas association's Blue Ridge member parks and closed 16. Texas Senate Bill 1, signed 5 September 2025, made Texas the first state to adopt NFPA 1194 statewide for RV parks and campgrounds, with weather alerting, evacuation training and emergency plans. Under USDA the environmental review under 7 CFR Part 1970 runs on its own track; under both programs a study should carry no rentable site revenue in a floodway or velocity zone in its base case, and a bindable insurance quote rather than a placeholder.

The rural-impact case, which only USDA scores. Appendix A's economic component includes "overall economic impact of project including new markets created and economic development," and the B&I priority point system under 7 CFR 5001.318 awards points for jobs at wages above 150% of the federal minimum, local ownership, distressed-community and high-unemployment locations, and lender pricing at or below Prime plus 1.5%. A USDA study that treats the economic component as boilerplate is leaving points and equity flexibility on the table. An SBA study has no equivalent section and should not pretend to.

The State Office. Under USDA the Agency determines the scope of the study, reviews it against Appendix A before commitment, and can require the lender "to obtain additional assistance in those areas where the lender does not have the necessary expertise." Expectations on recency, components and preparer vary by office, which is why the lender and consultant confirm scope and acceptability with the State Office before commissioning, not after. A study written for a PLP lender and submitted cold to a State Office is the most common cause of a returned USDA application in this asset class.

What the loan tape says about both paths

No public source publishes a default rate for NAICS 721211, so the answer comes from tabulating SBA's loan-level FOIA releases. Since fiscal 2010, roughly 929 approved 7(a) loans and 374 approved 504 loans, about $1.44 billion of supported capital, have gone to RV parks and campgrounds. Across all vintages the asset class charged off at 0.91% of disbursed 7(a) loans against 4.66% for the entire SBA book; on the fully seasoned 2010 to 2016 cohort, 2.63% against 6.11%, statistically indistinguishable from hotels and motels. In credit terms an RV park is a lodging asset and behaves like one.

Three cuts matter to the program decision. About 55.5% of RV park 504 loans since fiscal 2018 went to start-ups building parks from the ground up, against 29.6% on 7(a); the 504 is the construction lane and ground-up construction is the highest-risk profile in the asset class. Change-of-ownership loans, buying an operating park with a track record, show a zero trouble rate on the tape; building one from scratch does not. And the geography is not what the trade press implies: Texas leads with 13.3% of national loan count, but the four classic snowbird states together hold only 24%, while New York, Michigan, Wisconsin, Minnesota and Oregon hold 22%. SBA park lending is a northern, seasonal, distributed business, which is exactly the profile where the transient test is easiest to pass and the winter coverage hardest to carry. The median SBA note rate to the sector rose from 5.25% in fiscal 2021 to 9.87% in fiscal 2024, and that repricing is the reason the 40-year USDA term and the contracted-book coverage strategy have moved from the margin of the market to its center.

The pre-engagement checklist

1. Run the USDA eligibility map on the parcel and state the result in the engagement letter.
2. State the transient share of gross revenue from the operating history or the site and rate plan, and whether the sponsor intends to convert sites toward annual tenure.
3. Decide the program from location, tenure, size, term and equity before the study is scoped, and write the study to the stricter regime with the other's arithmetic added.
4. For USDA, confirm with the State Office that the author is acceptable and what scope the Agency requires; for SBA, confirm the lender's coverage floor and whether an 8.1 acquisition test applies.
5. Anchor demand to the installed base and usage, test the transient layer against the 2025 REIT softening, and count the trade-area pipeline.
6. Present coverage by month against the trough month's debt service, with the contracted book's share stated.
7. Restate the expense ratio to a market-managed basis with a reserve and a royalty where one applies, and carry a bindable insurance quote.
8. Treat floodway and velocity-zone sites as zero revenue in the base case and state the NFPA 1194 and state safety-code exposure.
9. Under USDA, write the economic component as the rural-development case the priority points reward; under SBA, do not.
10. State the SBA default record with its denominator and vintage, and place the subject's structure, acquisition or ground-up, against it.